1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 JANE DOE, f/k/a KRISTY ALTHAUS, CASE NO. 2:23-cv-07488-MWF-AGR an individual, 12 Judge Michael W. Fitzgerald Plaintiff, 13 DISCOVERY MATTER REFERRED v. TO MAGISTRATE JUDGE ALICIA 14 G. ROSENBERG AYLO GLOBAL ENTERTAINMENT 15 INC., a Delaware corporation; AYLO STIPULATED PROTECTIVE USA INCORPORATED, a Delaware ORDER 16 corporation; AYLO BILLING US CORP., a Delaware corporation; AYLO 17 HOLDINGS S.À.R.L., a foreign entity; NOTE CHANGES MADE BY AYLO FREESITES, LTD., d/b/a COURT 18 “PORN HUB,” a foreign entity; 9219- 1568 QUEBEC, INC., a foreign entity; 19 and AYLO PREMIUM LTD., a foreign corporation, 20 Defendants. 21 22 23 24 25 26 27 28 1 1. A. PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential, 3 proprietary, or private information for which special protection from public 4 disclosure and from use for any purpose other than prosecuting this litigation may 5 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 6 enter the following Stipulated Protective Order governing protected information 7 prior to trial in this case. The parties acknowledge that this Order does not confer 8 blanket protections on all disclosures or responses to discovery and that the 9 protection it affords from public disclosure and use extends only to the limited 10 information or items that are entitled to confidential treatment under the applicable 11 legal principles. The parties further acknowledge, as set forth in Section 12.5, below, 12 that this Stipulated Protective Order does not entitle them to file confidential 13 information under seal; Civil Local Rule 79-5 sets forth the procedures that must be 14 followed and the standards that will be applied when a party seeks permission from 15 the court to file material under seal. 16 B. GOOD CAUSE STATEMENT 17 Plaintiff’s Good Cause Statement: “It is ‘well-established’ in our case law 18 that discovery is ‘presumptively public.’” Cordero v. Stemilt AG Services, LLC, 142 19 F.4th 1201, 1207 (9th Cir. 2025) (quoting San Jose Mercury News, Inc. v. U.S. Dist. 20 Ct.—N. Dist. (San Jose), 187 F.3d 1096, 1103 (9th Cir. 1999)). Both the federal 21 common law and Federal Rules of Civil Procedure provide a right of access to court 22 records. San Jose, at 1099, 1101-02. “Generally, the public can gain access to 23 litigation documents and information produced during discovery unless the party 24 opposing disclosure shows ‘good cause’ why a protective order is necessary.” 25 Cordero, at 1207 (quoting Phillips ex rel. Ests. of Byrd v. Gen. Motors Corp., 307 26 F.3d 1206, 1210 (9th Cir. 2002) (Phillips)). In particular, the Ninth Circuit “strongly 27 favors access to discovery materials” for individuals engaged in other litigation 28 1 advances the interests of judicial economy by avoiding the wasteful duplication of 2 discovery.” Foltz v. State Farm Mut. Auto. Ins. Co., 331 F.3d 1122, 1131 (9th Cir. 3 2003). 4 “Rule 26(c) authorizes a district court to override this presumption [for public 5 records] where ‘good cause’ is shown.” San Jose, 187 F.3d at 1103. “If a court 6 finds particularized harm that would result from public disclosure it must ‘balance[] 7 the public and private interests to decide whether a protective order is necessary.’” 8 Cordero, at 1207 (quoting Phillips, 307 F.3d at 1211). 9 Due to the nature and notoriety of Plaintiff’s claims as a survivor of sex 10 trafficking, discovery in this Action will involve the production of Plaintiff’s private 11 and sensitive information for which special protection is warranted. There is a 12 compelling interest in protecting Plaintiff’s privacy and safety by shielding her 13 identifying information from the public. Plaintiff is routinely harassed, stalked, and 14 assaulted by members of the public related to the claims alleged in this Action. 15 Plaintiff has been forced to change her name. Plaintiff is expressly granted use of 16 the pseudonym “Jane Doe f/k/a Kristy Althaus” in this Action. In addition, both 17 federal and state sex trafficking, sexual assault, and other applicable rape shield laws 18 exist to protect the privacy of survivors like Plaintiff (including but not limited to 19 U.S. Const. Amend. XIV § 1, Fed. R. Evid. 412, Cal. Const., Art. 1 § 1, Cal. Evid. 20 Code §§ 782, 783, 1035.8, 1103, 1106, Cal. Code Civ. Proc. § 2017.220.) Plaintiff 21 therefore submits that there is good cause to protect Plaintiff’s identity, contact 22 information, location of residence, and other private or personally identifying 23 information from public disclosure with a protective order. 24 Furthermore, given the scope of this Action, it is impracticable to give notice 25 to each individual whose personal information may be the subject of discovery in 26 this Action, there is good cause for the protections and procedures set forth herein 27 to adequately protect against the improper disclosure or unauthorized use of third- 28 1 Defendants’1 Good Cause Statement: Defendants agree to protect 2 Plaintiff’s identity, contact information, location of residence, and other private or 3 personally identifying information from public disclosure with a protective order. 4 This Action is likely to involve discovery of corporate trade secrets, customer 5 and pricing lists and other valuable research, development, commercial, financial, 6 technical and/or proprietary information for which special protection from public 7 disclosure and from use for any purpose other than prosecution of this action is 8 warranted. Such confidential and proprietary materials and information consist of, 9 among other things, confidential business or financial information, information 10 regarding confidential business practices, or other confidential research, 11 development, or commercial information (including information implicating privacy 12 rights of third parties), system design, database design, algorithms, technology, 13 technical data or information, vendor agreements, claim/litigation information, 14 nonpublic policies and procedures, personal identifying information, sensitive 15 personal information, information otherwise generally unavailable to the public, or 16 which may be privileged or otherwise protected from disclosure under state, federal, 17 or foreign statutes, court rules, case decisions, or common law (including but not 18 limited to California Consumer Privacy Act, EU’s General Data Protection 19 Regulation, Canada’s Consumer Privacy Protection Act, and Quebec’s Act 20 Respecting The Protection of Personal Information In The Private Sector), or any 21 other information that a party is obligated to preserve as confidential, including all 22 information compiled, derived, excerpted, or generated from such materials. 23 Joint Statement: Accordingly, to expedite the flow of information, to 24 facilitate the prompt resolution of disputes over confidentiality of discovery 25 materials, to adequately protect information the parties are entitled to keep 26
27 1 “Defendants” are Aylo Global Entertainment Inc., Aylo USA Incorporated, Aylo Billing US Corp., Aylo Freesites Ltd, 9219-1568 Quebec Inc., Aylo Premium Ltd, 28 1 confidential, to ensure that the parties are permitted reasonable necessary uses of 2 such material in preparation for and in the conduct of trial, to address their handling 3 at the end of the litigation, and serve the ends of justice, a protective order for such 4 information is justified in this matter. It is the intent of the parties that information 5 will not be designated as confidential for tactical reasons and that nothing be so 6 designated without a good faith belief that each designated document has been 7 maintained in a confidential, non-public manner, and there is good cause why it 8 should not be part of the public record of this case. 9 10 2. DEFINITIONS 11 2.1 Action: this pending federal lawsuit, Jane Doe v. Aylo Global 12 Entertainment Inc. et al., No. 2:23-cv-07488-MWF-AGR (C.D. Cal.). 13 2.2 Challenging Party: a Party or Non-Party that challenges the 14 confidentiality designation of information or items in this Action. 15 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 16 how it is generated, stored or maintained) or tangible things that qualify for 17 protection under Federal Rule of Civil Procedure 26(c)—that is, information or 18 tangible things that, if disclosed, will cause a clearly defined and serious injury to 19 the Producing Party that outweighs the public’s interest in disclosure. Examples of 20 such information include: information protected by the U.S. Constitution or 21 California state Constitution rights to privacy (e.g., third-parties’ Social Security 22 Number, Medical Record Numbers, or taxpayer-identification numbers, names of 23 minor children, or financial account numbers); a Trade Secret; or research, 24 development, or commercial information that is of a highly competitively sensitive 25 nature and that a reasonably prudent business person in the applicable field would 26 not release to or share with the public in the ordinary course of business, and the 27 release of which would likely cause severe proprietary, competitive, or economic 28 1 does not include any information that: is publicly available at the time of disclosure; 2 becomes publicly available after disclosure through no fault of the Receiving Party; 3 was known to the Receiving Party prior to disclosure; the Receiving Party lawfully 4 receives at a later date from a third party without restriction as to disclosure; is 5 independently obtained through FOIA, CPRA, California Constitution Art. 1 § 3(b) 6 or other similar public records act; or was widely disseminated. See also Sections 7 12.3-12.4. 8 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 9 their support staff). 10 2.5 Designating Party: a Party or Non-Party that designates information or 11 items that it produces in disclosures or in responses to discovery as 12 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL.” The Designating Party 13 bears the burden of establishing good cause for the confidentiality of all such 14 information or items. 15 2.6 Disclosure or Discovery Material: all items or information, regardless 16 of the medium or manner in which it is generated, stored, or maintained (including, 17 among other things, testimony, transcripts, and tangible things), that are produced or 18 generated in disclosures or responses to discovery in this matter. 19 2.7 Expert: a person with specialized knowledge or experience in a matter 20 pertinent to the litigation who has been retained by a Party or its Counsel to serve as 21 an expert witness or as a consultant in this Action or for a greater scope of work that 22 includes this Action. This definition includes a professional jury or trial consultant 23 retained in connection with this Action. 24 2.8 “HIGHLY CONFIDENTIAL” Information or Items: information 25 (regardless of how it is generated, stored or maintained) or tangible things designated 26 as “HIGHLY CONFIDENTIAL” pursuant to the terms of this Order. HIGHLY 27 CONFIDENTIAL information or items consist of any CONFIDENTIAL 28 1 to extraordinary protections, or otherwise warrants such designation due to its 2 extreme sensitivity, propriety or personal nature such that, if disclosed, it will cause 3 a clearly defined injury to the Producing Party that outweighs the public’s interest 4 in disclosure. For example, Plaintiff’s PII (as defined in Paragraph 2.14 below) is 5 HIGHLY CONFIDENTIAL. During depositions, HIGHLY CONFIDENTIAL 6 information or items should be redacted from exhibits to the extent the information 7 is not necessary or related to the deponent’s testimony. 8 2.9 House Counsel: attorneys who are employees of a Party to this Action. 9 House Counsel does not include Outside Counsel of Record or any other outside 10 counsel. 11 2.10 Non-Party: any natural person, partnership, corporation, association, 12 or other legal entity not named as a Party to this action. 13 2.11 Outside Counsel of Record: attorneys who are not employees of a Party 14 to this Action but are retained to represent or advise a Party to this Action and have 15 appeared in this Action on behalf of that Party or are affiliated with a law firm which 16 has appeared on behalf of that Party, and includes support staff. 17 2.12 Party: any party to this Action, including all of its officers, directors, 18 employees, consultants, retained experts, and Outside Counsel of Record (and their 19 support staff). 20 2.13 Producing Party: a Party or Non-Party that produces Disclosure or 21 Discovery Material in this Action. 22 2.14 Plaintiff’s PII: Plaintiff’s personal identifying information including, 23 but not limited to, any private information which by a reasonable probability could 24 be used to identify or locate Plaintiff such as Plaintiff’s name(s), alias(es), date of 25 birth, telephone number(s), current and prior mailing and work addresses, email 26 address(es), medical records number(s), financial or tax record number(s), 27 educational & employment record number(s), social media, sexual history (outside 28 1 depictions of Plaintiff’s unique physical attributes or biometric data), social security 2 number, passport number, and driver’s license number. 3 2.15 Professional Vendors: persons or entities that provide litigation support 4 services (e.g., photocopying, videotaping, translating, preparing exhibits or 5 demonstrations, organizing, storing, or retrieving data in any form or medium, or 6 court reporters, stenographers, videographers) and their employees and 7 subcontractors. 8 2.16 Protected Material: any Disclosure or Discovery Material that is 9 designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL” in accordance 10 with Section 5 (Designating Protected Material), unless the confidentiality 11 designation is challenged and: (a) the Court decides such material is not entitled to 12 protection as confidential; (b) the Designating Party fails to apply to the Court for 13 an order holding that the material is entitled to protection within the time period 14 specified below; or (c) the Designating Party withdraws its confidentiality 15 designation in writing. 16 2.17 Receiving Party: a Party that receives Disclosure or Discovery Material 17 from a Producing Party. 18 2.18 Trade Secret(s): information like a formula, pattern, compilation, 19 program, device, method, technique, or process that the holder took reasonable 20 precautions to prevent disclosing publicly and that: (i) derives independent economic 21 value, actual or potential, from not being generally known to, and not being readily 22 ascertainable by proper means by other persons who can obtain economic value from 23 its disclosure or use; and (ii) is the subject of efforts that are reasonable under the 24 circumstances to maintain its secrecy. 25 26 3. SCOPE 27 The protections conferred by this Stipulation and Order cover not only 28 1 extracted from Protected Material; (2) all copies, excerpts, summaries, or 2 compilations of Protected Material; and (3) any testimony, conversations, or 3 presentations by Parties or their Counsel that might reveal Protected Material. 4 Any use of Protected Material at trial shall be governed by the orders of the 5 trial judge. This Order does not govern the use of Protected Material at trial. 6 See Sections 4 & 13. Nothing in this Order shall be construed as an agreement by 7 any Party as to whether any other Party will be able to demonstrate good cause or 8 compelling reasons, as applicable, to seal any material in any filing on the docket or 9 at trial. 10 11 4. DURATION 12 Even after final disposition of this litigation, the confidentiality obligations imposed 13 by this Order shall remain in effect until a Designating Party agrees otherwise in 14 writing or a court order otherwise directs. Final disposition shall be deemed to be 15 the later of: (1) dismissal of all claims and defenses in this Action, with or without 16 prejudice; and (2) final judgment herein after the completion and exhaustion of all 17 appeals, rehearings, remands, trials, or reviews of this Action, including the time 18 limits for filing any motions or applications for extension of time pursuant to 19 applicable law. However, this Order does not govern the use of Protected Material 20 at trial. Protected Material used at trial becomes public absent a separate court order 21 upon motion supported by a legally sufficient showing. The Parties agree that the 22 use and disclosure of Protected Material at trial shall be governed by a separate 23 stipulated protective order to be entered for purposes of trial (“Trial Protective 24 Order”). Protected Material that was designated as Confidential or Highly 25 Confidential in discovery shall not be given any presumption of confidentiality at 26 trial, but rather shall be assessed based on the Trial Protective Order, which shall be 27 facilitated by agreement of the Parties or as determined by the Court through 28 1 controlling case law and relevant public policy. Until the Trial Protective Order is 2 entered, Protected Material may not be used or disclosed at trial. 3 4 5. DESIGNATING PROTECTED MATERIAL 5 5.1 Exercise of Restraint and Care in Designating Material for Protection. 6 Each Party or Non-Party that designates information or items for protection under 7 this Order must take care to limit any such designation to specific material that 8 qualifies under the appropriate standards. The Designating Party must designate for 9 protection only those parts of material, documents, items, or oral or written 10 communications that qualify for good cause, so that other portions of the material, 11 documents, items, or communications for which protection is not warranted are not 12 swept unjustifiably within the ambit of this Order. 13 Mass, indiscriminate, or routinized designations are prohibited. Designations 14 that are shown to be clearly unjustified or that have been made for an improper 15 purpose (e.g., to unnecessarily encumber the case development process or to impose 16 unnecessary expenses and burdens on other parties) may expose the Designating 17 Party to sanctions. 18 5.2 Redaction Protocol. Producing Parties shall designate information or 19 items in a way that provides the greatest level of disclosure possible, while still 20 preserving confidentiality where necessary. Each Designating Party must use good 21 faith efforts to limit any such designation to the specific material that qualifies for 22 protection. If only part of a document contains CONFIDENTIAL or HIGHLY 23 CONFIDENTIAL information, the whole document shall not be designated 24 confidential. Instead, whenever it is feasible and not unduly burdensome to protect 25 non-responsive CONFIDENTIAL or HIGHLY CONFIDENTIAL information 26 through targeted redactions, the Designating Party shall use redactions in lieu of 27 blanket confidentiality designations. Redactions to Plaintiff’s PII and third-party 28 1 Federal Rule of Civil Procedure 5.2. Redactions shall be narrowly tailored to the 2 specific information claimed to be protected (e.g., personal identifiers or Trade 3 Secrets), and the remainder of the document shall remain public and not designated 4 as confidential. 5 If it comes to a Designating Party’s attention that information or items that it 6 designated for protection do not qualify for protection, that Designating Party must 7 promptly notify all other Parties that it is withdrawing the inapplicable designation. 8 5.3 Manner and Timing of Designations. Except as otherwise provided in 9 this Order (see, e.g., second paragraph of section 5.3(a) below), or as otherwise 10 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 11 under this Order must be clearly so designated before the material is disclosed or 12 produced. 13 Designation in conformity with this Order requires: 14 (a) For information in documentary form (e.g., paper or electronic 15 documents, but excluding transcripts of depositions or other pretrial or trial 16 proceedings), that the Producing Party affix at a minimum, the legend 17 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL” (hereinafter 18 “CONFIDENTIAL legend” or “HIGHLY CONFIDENTIAL legend”), to each page 19 that contains protected material. If only a portion or portions of the material on a 20 page qualifies for protection, the Producing Party also must clearly identify the 21 protected portion(s) (e.g., by making redactions or appropriate markings in the 22 margins). 23 A Party or Non-Party that makes original documents available for inspection 24 need not designate them for protection until after the inspecting Party has indicated 25 which documents it would like copied and produced. During the inspection and 26 before the designation, all of the material made available for inspection shall be 27 deemed “HIGHLY CONFIDENTIAL.” After the inspecting Party has identified the 28 1 documents, or portions thereof, qualify for protection under this Order. Then, before 2 producing the specified documents, the Producing Party must affix the 3 “CONFIDENTIAL legend” or “HIGHLY CONFIDENTIAL legend” to each page 4 that contains Protected Material. If only a portion or portions of the material on a 5 page qualifies for protection, the Producing Party also must clearly identify the 6 protected portion(s) (e.g., by making appropriate redactions or markings in the 7 margins). 8 (b) For testimony given in depositions or other pretrial proceedings that the 9 Designating Party identifies the Protected Material on the record, before the close of 10 the deposition or other pretrial proceeding. Alternatively, any Party may designate 11 testimony as Protected Material by notifying all Parties in writing not later than 30 12 days after receipt of the deposition transcript of the specific pages and lines of the 13 transcript that should be treated as Protected Material. If only a portion or portions 14 of the material on a page qualifies for protection, the Producing Party also must 15 clearly identify the protected portion(s) by page and line designations. All 16 deposition transcripts shall be treated as “CONFIDENTIAL” for a period of 30 days 17 after initial receipt of the transcript. 18 (c) For information produced in some form other than documentary and for 19 any other tangible items, that the Producing Party affix in a prominent place on the 20 exterior of the container or containers in which the information is stored the legend 21 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL.” If only a portion or portions 22 of the information warrants protection, the Producing Party, to the extent practicable, 23 shall identify the protected portion(s) in a way that does not interfere with the 24 viewing of the evidence. 25 5.4 Inadvertent Failures to Designate. If timely corrected, an inadvertent 26 failure to designate qualified information or items does not, standing alone, waive 27 the Designating Party’s right to secure protection under this Order for such material. 28 1 efforts to assure that the material is treated in accordance with the provisions of this 2 Order. 3 5.5 Privilege Logs. Pursuant to Federal Rule of Civil Procedure Rule 4 26(b)(5), a Producing Party will produce a Privilege Log describing the nature of 5 any withheld information at the time of production. The Parties agree that privileged 6 attorney-client communications and work product made after the filing of this 7 Action (September 8, 2023) need not be included on the Privilege Logs. 8 9 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 10 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 11 designation of confidentiality at any time that is consistent with the Court’s 12 Scheduling Order. While every effort will be made to timely challenge the 13 Designating Party’s confidentiality designations to avoid foreseeable substantial 14 unfairness, unnecessary economic burdens, and significant disruption or delay of the 15 litigation, a Party does not waive or inhibit its right to challenge a confidentiality 16 designation by electing not to mount a challenge immediately after the original 17 designation is disclosed. 18 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 19 resolution process under Local Rule 37.1 et seq. and in accordance with the 20 procedures for discovery motions set forth on Magistrate Judge Rosenberg’s 21 website. Within ten (10) days of the Challenging Party’s request for a L.R. 37-1 22 prefiling conference, the Designating Party must explain, in writing, the basis for 23 each challenged confidentiality designation it intends to maintain. 24 6.3 Burden. The burden of persuasion in any such challenge proceeding 25 shall be on the Designating Party. If neither the designation nor the objection is 26 withdrawn following the discovery conference before Magistrate Judge Rosenberg, 27 the Designating Party shall have twenty (20) days from said discovery conference, 28 1 file a motion requesting that the Court determine whether the challenged material is, 2 in fact, entitled to protection under this Order. The Designating Party must make a 3 particular and specific demonstration of fact supporting good cause for each 4 document, information, or item it seeks to protect by showing that specific prejudice 5 or harm will result if no protection is granted. 6 Unless the Designating Party has waived or withdrawn the confidentiality 7 designation, all parties shall continue to afford the material in question the level of 8 protection to which it is entitled under the Producing Party’s designation until the 9 Court rules on the challenge or, if no motion is made, until the time for the 10 Designating Party to bring a motion has expired. Failure by the Designating Party 11 to make such a motion within the applicable time period for doing so shall 12 automatically waive the confidentiality designation for each challenged designation. 13 Frivolous challenges or confidentiality designations, and those made for an improper 14 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 15 parties) may expose the Challenging or Designating Party to sanctions. 16 6.4 Procedure for Non-Parties. A Non-Party may challenge a Designating 17 Party’s confidentiality designation(s) only to the extent consistent with the Federal 18 Rules of Civil Procedure or case law. by filing a motion to intervene in the Action 19 for the purpose of challenging the confidentiality designation(s). The Designating 20 Party bears the burden of establishing that the challenged material is entitled to 21 protection. 22 23 7. ACCESS TO AND USE OF PROTECTED MATERIAL 24 7.1 Basic Principles. A Receiving Party may use Protected Material that is 25 disclosed or produced by another Party or by a Non-Party in connection with this 26 Action only for prosecuting, defending, or attempting to settle this Action. Such 27 Protected Material may be disclosed only to the categories of persons and under the 28 1 Receiving Party must comply with the provisions of section 13 below (FINAL 2 DISPOSITION). 3 Protected Material must be stored and maintained by a Receiving Party at a 4 location and in a secure manner that ensures that access is limited to the persons 5 authorized under this Order. 6 7.2 Disclosure of “CONFIDENTIAL” Information or Items. With the 7 exception of a third-party’s personal identifying information which should always 8 be redacted in documents filed publicly pursuant to L.R. 5.2-1, Unless otherwise 9 ordered by the Court herein or hereafter, or permitted in writing by the Designating 10 Party, a Receiving Party may disclose any information or item designated 11 “CONFIDENTIAL” only to: 12 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 13 as employees of said Outside Counsel of Record to whom it is reasonably necessary 14 to disclose the information for this Action such as litigation assistants, paralegals, 15 and secretarial and other clerical personnel; 16 (b) the officers, directors, and/or their equivalent under foreign law of the 17 Receiving Party to whom disclosure is reasonably necessary for this Action; 18 (c) the employees and consultants (including House Counsel) of the 19 Receiving Party to whom disclosure is reasonably necessary for this Action; 20 (d) the Parties; 21 (e) Experts (as defined in this Order) of the Receiving Party to whom 22 disclosure is reasonably necessary for this Action and who have signed the 23 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 24 (f) the court and its personnel; 25 (g) professional jury or trial consultants, and mock jurors to whom 26 disclosure is reasonably necessary for this Action and who have signed the 27 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 28 1 (h) Professional Vendors to whom disclosure is reasonably necessary for 2 this Action; 3 (i) the author or recipient of a document containing the information or a 4 custodian or other person who otherwise possessed or knew the information; 5 (j) deposition witnesses, and attorneys for witnesses, in the Action to 6 whom disclosure is reasonably necessary provided: (1) the deposing party requests 7 that the witness signs the form attached as Exhibit A hereto; and (2) they will not be 8 permitted to keep any confidential information unless they sign the 9 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 10 agreed by the Designating Party or ordered by the court; 11 (k) counsel for issuers of insurance policies under which any issuer may be 12 liable to satisfy part or all of a judgment that may be entered in this Action or to 13 indemnify or reimburse payments or costs associated with this Action; 14 (l) any mediator or settlement officer, and their supporting personnel, 15 mutually agreed upon by any of the parties engaged in settlement discussions; and 16 (m) any other person as to whom the Producing Party has consented to 17 disclosure in advance and in writing. 18 7.3 Disclosure of “HIGHLY CONFIDENTIAL” Information or Items. If 19 a Party wishes to file information containing Plaintiff’s PII with the Court, the 20 information must be redacted and filed conditionally under seal pursuant to Local 21 Rules such that Plaintiff’s PII is not publicly disclosed unless ordered by the court. 22 Unless otherwise ordered by the Court or permitted in writing by the Designating 23 Party, a Receiving Party may disclose any other information or item designated 24 “HIGHLY CONFIDENTIAL” only to: 25 (a) the Receiving Party’s Outside Counsel of Record in this Action and 26 House Counsel, as well as employees of said Outside Counsel of Record and House 27 Counsel to whom it is reasonably necessary to disclose the information for the 28 1 Action such as litigation assistants, paralegals, and secretarial and other clerical 2 personnel; 3 (b) Experts (as defined in this Order) of the Receiving Party to whom 4 disclosure is reasonably necessary for any of the Action and who have signed the 5 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 6 (c) the court and its personnel; 7 (d) court reporters and their staff; 8 (e) professional jury or trial consultants, and mock jurors to whom 9 disclosure is reasonably necessary for the Action and who have signed the 10 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 11 (f) Professional Vendors to whom disclosure is reasonably necessary for 12 the Action; 13 (g) the author or recipient of a document containing the information or a 14 custodian or other person who otherwise possessed or knew the information; 15 (h) during their depositions, witnesses, and attorneys for witnesses, in the 16 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 17 requests that the witness signs the form attached as Exhibit A hereto; and (2) the 18 witness will not be permitted to keep any confidential information unless they sign 19 the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 20 agreed by the Designating Party or ordered by the Court. Pages of transcribed 21 deposition testimony or exhibits to depositions that reveal Highly Confidential 22 Protected Material may be separately bound by the court reporter and may not be 23 disclosed to anyone except as permitted under this Stipulated Protective Order; 24 (i) Upon written request to and permission from the Designating Party, 25 which shall be fairly and reasonably given, to a deponent or witness who was noticed 26 for a deposition or is on a witness list for hearing or trial in the Action, in preparation 27 for his or her noticed deposition, or hearing, or trial testimony, who does not qualify 28 1 information is determined by counsel in good faith to be necessary to the anticipated 2 subject matter of testimony. Such Highly Confidential information shall only be 3 shared with such person in connection with preparation for the anticipated testimony, 4 and the person identified in this paragraph will not be permitted to retain copies of 5 such Highly Confidential information and shall be required to sign the 6 “Acknowledgment and Agreement to Be Bound” (Exhibit A). 7 (j) any mediator or settlement officer, and their supporting personnel, 8 mutually agreed upon by any of the parties engaged in settlement discussions; and 9 (k) any other person as to whom the Producing Party has consented to 10 disclosure in advance and in writing. 11 7.4 Disclosure to the Government or Other Third Party. Notwithstanding 12 this Order or any confidentiality designations under it, any Party may disclose 13 relevant information to any regulatory or law enforcement agency, or government 14 entity, or third party that has an interest in the subject matter of the Action if 15 compelled to do so by a subpoena or other legal process. In such case, the procedure 16 set forth in Paragraph 8, below, shall apply. 17 18 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 19 IN OTHER LITIGATION 20 If a Party is served with a subpoena or a court order issued in other litigation 21 that compels disclosure of any Protected Material, that Party must: 22 (a) promptly notify in writing the Designating Party within five (5) 23 business days after receiving the subpoena or court order, and such notification shall 24 include a copy of the subpoena or court order; 25 (b) promptly notify in writing the party who caused the subpoena or order 26 to issue in the other litigation that some or all of the material covered by the subpoena 27 or order is subject to this Protective Order. Such notification shall include a copy of 28 1 (c) cooperate with respect to all reasonable procedures sought to be 2 pursued by the Designating Party whose Protected Material may be affected. 3 If the Designating Party timely seeks a protective order from the court where 4 the subpoena or order issued, the Party served with the subpoena or court order shall 5 not produce any information designated in this action as “CONFIDENTIAL” or 6 “HIGHLY CONFIDENTIAL” before a determination by the court from which the 7 subpoena or order issued, unless the Party has obtained the Designating Party’s 8 permission. The Designating Party shall bear the burden and expense of seeking 9 protection in that court of its confidential material and nothing in these provisions 10 should be construed as authorizing or encouraging a Receiving Party in this Action 11 to disobey a lawful directive from another court. 12 13 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 14 PRODUCED IN THIS LITIGATION 15 (a) The terms of this Order are applicable to information produced by a 16 Non-Party in this Action and designated as “CONFIDENTIAL” or “HIGHLY 17 CONFIDENTIAL.” Such information produced by Non-Parties in connection with 18 this litigation is protected by the remedies and relief provided by this Order. Nothing 19 in these provisions should be construed as prohibiting a Non-Party from seeking 20 additional protections. 21 (b) In the event that a Party is required, by a valid discovery request, to 22 produce a Non-Party’s confidential information in its possession, and the Party is 23 subject to an agreement with the Non-Party not to produce the Non-Party’s 24 confidential information, then the Party shall: 25 (1) promptly notify in writing the Requesting Party and the Non- 26 Party that some or all of the information requested is subject to a confidentiality 27 agreement with a Non-Party; 28 1 (2) promptly provide the Non-Party with a copy of the Stipulated 2 Protective Order in this Action, the relevant discovery request(s), and a reasonably 3 specific description of the information requested; and 4 (3) make the information requested available for inspection by the 5 Non-Party, if requested. 6 (c) If a Party or the Non-Party fails to seek a protective order from this 7 court within 14 days of receiving the notice and accompanying information, the 8 Receiving Party may produce the Non-Party’s confidential information responsive 9 to the discovery request. If the Non-Party timely seeks a protective order, the 10 Receiving Party shall not produce any information in its possession or control that 11 is subject to the confidentiality agreement with the Non-Party before a determination 12 by the court. Absent a court order to the contrary, the Non-Party shall bear the burden 13 and expense of seeking protection in this court of its Protected Material. 14 15 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 16 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 17 Protected Material to any person or in any circumstance not authorized under this 18 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 19 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 20 to retrieve all unauthorized copies of the Protected Material, (c) inform the person 21 or persons to whom unauthorized disclosures were made of all the terms of this 22 Order, and (d) request such person or persons to execute the “Acknowledgment and 23 Agreement to Be Bound” that is attached hereto as Exhibit A. 24 25 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 26 PROTECTED MATERIAL 27 When a Producing Party gives notice to Receiving Parties that certain 28 1 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 2 Procedure 26(b)(5)(B). The inadvertent production of privileged or work-product 3 protected documents, electronically stored information (“ESI”) or information is not 4 on its own a waiver of the privilege or protection from discovery in this case or in 5 any other federal or state proceeding. If the Receiving Party has reason to believe 6 that a produced document or other information may reasonably be subject to a claim 7 of privilege, then the Receiving Party shall immediately sequester the document or 8 information, and shall inform the Producing Party of the beginning BATES number 9 of the document or, if no BATES number is available, shall otherwise inform the 10 producing party of the information. 11 Any Party or Non-Party that inadvertently discloses or produces a Document, 12 ESI, or information that it considers privileged or otherwise protected from 13 discovery will, promptly upon discovery of the disclosure or production, give notice 14 to the Receiving Party, identifying the document, ESI, or information in question; 15 the asserted privilege or protection; and the grounds therefor. 16 Upon receipt of notice of the assertion of privilege or protection over produced 17 documents, ESI, or information, the Receiving Party will: 18 (a) to whatever extent it contests the assertion of privilege or protection, 19 promptly so notify the Producing Party or Non-Party, and maintain the contested 20 documents and ESI in confidence pending resolution of the contest by the parties or 21 the court; and 22 (b) to whatever extent the Receiving Party does not contest the assertion of 23 privilege or protection, promptly certify in writing to the Producing Party or Non- 24 Party that it has returned or destroyed and does not maintain any copies of the 25 applicable document(s), ESI, and/or information, and has made reasonably diligent 26 efforts to identify and destroy each copy thereof and all information derived 27 therefrom. 28 1 In the event of a contested assertion of privilege or protection over produced 2 documents that cannot be resolved amicably after meeting and conferring in good 3 faith, the Producing Party may promptly seek resolution of the matter in accordance 4 with the court’s Local Rules and the Federal Rules of Civil Procedure, including by 5 seeking in camera review. 6 7 12. MISCELLANEOUS 8 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 9 person to seek its modification by the Court in the future. 10 12.2 Right to Assert Other Objections. By stipulating to the entry of this 11 Protective Order no Party waives any right it otherwise would have to object to 12 disclosing or producing any information or item on any ground not addressed in this 13 Stipulated Protective Order. Similarly, no Party waives any right to object on any 14 ground to use in evidence of any of the material covered by this Protective Order. 15 12.3 Prior or Public Knowledge. This Protective Order shall not apply to 16 information that, prior to disclosure, is public knowledge, and the restrictions 17 contained in this Protective Order shall not apply to information that is, or after 18 disclosure becomes, public, including but not limited to, information that was used 19 in a public agency proceeding or a governmental hearing; was in the possession of 20 the Party to whom disclosure is made prior to disclosure; is public knowledge other 21 than by an act or omission of the party to whom such disclosure is made; or that is 22 legitimately and independently acquired from a source not subject to this Protective 23 Order. Notwithstanding this section, Plaintiff’s PII is always HIGHLY 24 CONFIDENTIAL and shall always be redacted or omitted from publicly filed 25 documents for purposes of discovery unless otherwise ordered by the court. 26 12.4 GirlsDoPorn (GDP). This Action relates to the GDP sex trafficking 27 criminal enterprise and the facts and findings in related cases and prosecutions 28 1 thereof, including, but not limited to, in Jane Doe Nos. 1-22 v. GirlsDoPorn.com et 2 al. (Cal. Super. Ct. No. 37-2016-00019027-CU-FR-CTL). 3 12.5 Filing Protected Material. Neither this Order, nor any confidentiality 4 designation under it, is a sufficient basis for demonstrating that court records may be 5 sealed. A Party that seeks to file under seal any Protected Material must comply with 6 Civil Local Rule 79-5. Protected Material may only be filed under seal pursuant to a 7 court order authorizing the sealing of the specific Protected Material at issue. If a 8 Party's request to file Protected Material under seal is denied by the court, then the 9 Receiving Party may file the information in the public record unless otherwise 10 instructed by the court. 11 12.6 Non-Parties. Nothing in this Order affects the right of Non-Parties to 12 this Action to challenge this Order, any confidentiality designations made pursuant 13 to this Order, or the sealing of any court records in this Action. 14 15 13. FINAL DISPOSITION 16 Even after final disposition of this litigation, the confidentiality obligations 17 imposed by this Order shall remain in effect until a Designating Party agrees 18 otherwise in writing or a court order otherwise directs. Final disposition shall be 19 deemed to be the later of: (1) dismissal of all claims and defenses in this Action, with 20 or without prejudice; and (2) final judgment herein after the completion and 21 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 22 including the time limits for filing any motions or applications for extension of time 23 pursuant to applicable law. 24 25 26 27 28 1 14. VIOLATION. Any violation of this Order may be punished by any and all 2 appropriate measures including, without limitation, contempt proceedings and/or 3 monetary sanctions. 4 5 6 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 7 Dated: November 11, 2025 BOUCHER LLP 8
9 BURG SIMPSON ELDREDGE HERSH & JARDINE, P.C. 10 11 12 By: /s/ Amanda J.G. Walbrun Raymond P. Boucher 13 Amanda J.G. Walbrun David K. TeSelle 14 Morgan L. Carroll
15 Attorneys for Plaintiff Jane Doe 16
18 Dated: November 11, 2025 MITCHELL SILBERBERG & KNUPP LLP 19 20 By: /s/ Emily F. Evitt 21 David A. Steinberg Marc E. Mayer 22 Emily F. Evitt
23 Attorneys for Defendants 24 25 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 26 27 DATED: November 13, 2025 28 Honorable Alicia G. Rosenberg 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, [print or type full name], 5 of [print or type full address], declare under penalty of 6 perjury that I have read in its entirety and understand the Stipulated Protective Order 7 that was issued by the United States District Court for the Central District of 8 California in the case of Jane Doe v. Aylo Global Entertainment Inc. et al., No. 9 2:23-cv-07488-MWF-AGR (C.D. Cal.). I agree to comply with and to be bound by 10 all the terms of this Stipulated Protective Order and I understand and acknowledge 11 that failure to so comply could expose me to sanctions and punishment in the nature 12 of contempt. I solemnly promise that I will not disclose in any manner any 13 information or item that is subject to this Stipulated Protective Order to any person 14 or entity except in strict compliance with the provisions of this Order. I further agree 15 to submit to the jurisdiction of the United States District Court for the Central 16 District of California for the purpose of enforcing the terms of this Stipulated 17 Protective Order, even if such enforcement proceedings occur after termination of 18 this action. I hereby appoint [print or type full 19 name] of [print or type full address 20 and telephone number] as my California agent for service of process in connection 21 with this Action or any proceedings related to enforcement of this Stipulated 22 Protective Order. 23 Date: 24 City and State where sworn and signed: 25 26 Printed name: 27 28 1 Signature: 2 3 Attestation Regarding Signatures-Local Rule 5-4.3.4(a)(2)(i) 4 I, Emily F. Evitt, attest that all signatories listed, and on whose behalf the 5 filing is submitted, concur in the filing’s content and have authorized the filing. 6
7 Dated: November 13, 2025 /s/ Emily F. Evitt Emily F. Evitt 8
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28